Zavee’s infringement will continue unless enjoined by this Court.11.
Zavee has caused Rewards Network to suffer, and unless enjoined by this Court,will cause Rewards Network to continue to suffer substantial injury, including lost profits, for which Rewards Network is entitled to damages adequate to compensate it for Zavee’sinfringement.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Rewards Network respectfully requests judgment and relief against Zavee as follows:A.
A judgment that Zavee has infringed the '841 Patent;B.
An injunction against Zavee, its subsidiaries, affiliates, parents, successors,assignees, officers, agents, servants, employees, and all persons acting in concert or in participation with them, or any of them, permanently enjoining each of them from infringing,contributing to, or inducing the infringement of the '841 Patent;C.
Awarding Rewards Network damages adequate to compensate for Zavee’sinfringement of the '841 Patent, but in no event less than a reasonable royalty on Zavee’s use of Rewards Network’s invention;D.
Awarding pre-judgment interest on any damages award;E.
Adjudging that Zavee’s infringement of the '841 Patent is willful, and increasingZavee’s liability for damages up to three times the amount found or assessed;F.
Declaring that this is an exceptional case under 35 U.S.C. § 285, and for an award of increased damages, attorneys’ fees, and costs; and G.
Granting such other and further relief as the Court deems just and proper.